HomeMy WebLinkAbout87-616 ZotterDear Ms. Zotter:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (717) 783 -1610
October 16, 1987
ADVICE OF COUNSEL
Ms. Sandra Zotter
168 Link Avenue 87 -616
Pittsburgh, PA 15237
Re: Conflict of Interest, Township Commissioner, Spouse employed by Police
Department
This responds to your letter of September 15, 1987, wherein you requested
the advice of the State Ethics Commission.
Issue: Whether the State Ethics Act places any prohibitions upon a township
commissioner in voting on matters regarding the police department when her
spouse is a sergeant in the township police department.
Facts: You have been appointed as a commissioner in Ross Township. Your
husband is a police sergeant in the Ross Township Police Department. You ask
what restrictions would apply to you regarding voting on matters concerning
the police department.
Discussion: As a township commissioner, you are a public official as that
term is defined in the State Ethics Act. 65 P.S. §402. As such, to the provisions of the Ethics Act and the restrictions �therein
applicable to you.
Section 3(a) of the Ethics Act provides:
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
Ms. Sandra Zotter
October 16, 1987
Page 2
Section 3(a) basically provides that a public official may not use his
public position or confidential information in order to obtain financial gain
for himself or a member of his immediate family. The above provision would
encompass participating, to any extent, in a matter that related to the public
official or to a member of his immediate family. The Ethics Act defines
member of one's immediate family as follows:
Section 2. Definitions.
"Immediate family." A spouse residing in the person's
household and minor dependent children. 65 P.S. 402.
Mr. Zotter is clearly a member of your immediate family as defined in the
State Ethics Act. As such, you would be prohibited from usin
office in order to obtain a financial u 9 your p
gain vote nor participate in any matterthatfwouldresultain�financialo could
your husband. gain to
Section 3(b) of the Ethics Act provides:
Section 3. Restricted activities.
(b) No person shall offer or give to a public official or
public employee or candidate for public office or a member
of his immediate family or a business with which he is
associated, and no public official or public employee or
candidate for public office shall solicit or accept,
anything of value, including a gift, loan, political
contribution, reward, or promise of future employment
based on any understanding that the vote, official action,
or judgment of the public official or public employee or
candidate for public office would be influenced thereby.
65 P.S. 403(b).
Finally, reference to Section 3(b) of the Ethics Act must be made in
order to provide a complete response to your inquiry. Under Section 3(b) of
the Ethics Act cited above, which you must observe, you must neither offer nor
accept anything of value on the understanding or with the intention that your
official judgment would be influenced thereby. It is assumed such a situation
does not exist here. Reference to this Section is added not to indicate that
any such activity has been or will be undertaken but in an effort to provide a
complete response to your inquiry.
Under the Ethics Act, the Commission may address other areas of possible
conflicts of interests. See 65 P.S. §403(d). The parameters of the
activities encompassed by this provision generally are determined through a
Ms. Sandra Zotter
October 16, 1987
Page 3
review of the intent and purpose of the Ethics Act. The Ethics Act was
promulgated in order to insure the public that the financial interests of
their officials do not conflict with the public trust. In this respect, you
are advised, that in the event that the township commissioners are called upon
to address an issue which somehow would relate to or directly affect your
husband, you must abstain from participating in such matter. It is noted that
your abstention would only be required in those situations wherein the
township action would somehow enure to the benefit of your husband. If such a
situation should arise, the fact that you have abstained from participating in
the matter should be publicly noted and appropriately recorded in the township
minutes. The reason for your abstention should also be noted.
Lastly, the Ethics Commission has only addressed your question under the
Ethics Act; it has not considered the applicability of any other statute,
code, ordinance, regulation, or other code of conduct.
Conclusion: As the township commissioner, you are a public official subject
to the provisions of the State Ethics Act. As outlined above, there is no per
se prohibition to your voting on matters relating to the police department.
However, you must abstain from participating in those situations wherein the
township action would somehow enure to the benefit of your husband. Further,
your abstention from participation should be publicly noted and appropriately
recorded in the township minutes. The reason for your abstention should also
be noted.
Pursuant to Section 7(9)(ii), this Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, providing the requestor has
disclosed truthfully all the material facts and committed the acts complained
of in reliance on the Advice given.
This letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any reason to
challenge same, you may request that the full Commission review this Advice. A
personal appearance before the Commission will be scheduled and a formal
Opinion from the Commission will be issued. Any such appeal must be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
Sincerely,
1J c
Vincent J. Dopko
General Counsel